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Home My WebLink AboutAQ_F_0300033_20211103_CMPL_InspRpt (4) i NORTH CAROLINA DIVISION OF Winston-Salem Regional Office AIR QUALITY Alleghany Stone,LLC NC Facility ID 0300033 Inspection Report County/FIPS:Alleghany/005 Date: 11/03/2021 Facility Data Permit Data Alleghany Stone,LLC Permit 07832/R04 367 Arbor Lane Issued 3/7/2014 Glade Valley,NC 28627 Expires 2/28/2022 Lat: 36d 27.3960m Long: 81d 1.8240m Class/Status Small SIC: 1429/Crushed And Broken Stone Nec Permit Status Active NAICS: 212319/Other Crushed and Broken Stone Mining and Quarrying Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP Chris Barrett Chris Barrett Chris Barrett NSPS: Subpart 000 Manager Manager Manager (336)372-5222 (336)372-5222 (336)372-5222 Compliance Data Comments: Inspection Date 11/03/2021 Inspector's Name Ryan Dyson Inspector's Signature: DMM Operating Status Operating Compliance Status Compliance-inspection Action Code FCE Date of Signature: Ir(1 L 12O Z� Inspection Result Deficiency Total Actual emissions in TONSIYEAR: TSP S02 NOX VOC CO PM10 *HAP 2012 0.2000 0.1700 3.39 0.1900 0.7800 0.1400 1.53 2003 0.0000 --- --- --- --- --- Highest HAP Emitted in ounds Five Year Violation History:None Date Letter Tyne Rule Violated Violation Resolution Date Performed Stack Tests since last FCE:None Date Test Results Test Method(s) Source(s)Tested 1 Permitted Emission Sources Emissions Emissions Source Control __F Control System Source ID � Description System ID Description FNon-metallic mineral processing plant utilizing water suppression,with no other control devices ...... ..... .......................::......... ...............:..........................................................................................................................:......................................................................................................................................................:...................................................:...............................................................:...........:.......... .......................... ........................................ ES-Cr......ush ( Crushing operations ES-Screen Screening operations N/A ( N/A ( ES-Convey Conveying operations Insignificant/Exempt Activities _ s Exemption Source of Source of Title V Source ( ) Regulation TAPS? Pollutants? IES-1 —Diesel-fired portable generator(510 kW maximum rated capacity output; 2Q .0 102 _ No approximately 635 hp rated capacity engine) I(c)(1)(L)(iii) . : Yes IES-2—Aboveground storage tank containing diesel fuel(500 gallons capacity) 2Q.0102 Yes IES-4—Aboveground storage tank containing diesel fuel(2,500 gallons capacity) I (c)(1)(D)(i) Introduction On November 3,2021,Mr.Ryan Dyson,Environmental Specialist for the Winston-Salem Regional Office of the North Carolina Division of Air Quality(WSRO-DAQ),met with Mr.Chris Barrett,Manager,Ms.Vickie Bach,Office Manager,and Mr.John Huss, Plant Manager,and conducted a Full Compliance Evaluation(FCE)of Alleghany Stone,LLC.The facility was most recently inspected by Mr.Paul Williams,Former Environmental Specialist for the WSRO-DAQ,on October 16,2018,and appeared to be operating in compliance with all applicable Air Quality standards and regulations at that time.The facility is a rock crushing operation that operates 8 hours per day and 5 days per week,on a seasonal basis.Mr.Barrett indicated that the facility does not typically engage in crushing between December and March.All IBEAM contact information was confirmed at the time of this inspection.However, Mr.Barrett noted that he is typically only on-site Mondays through Wednesdays. If future inspectors come on-site on a Thursday or Friday,they will likely meet with Ms.Bach or Mr.Huss. Safety Equipment Proper Personal Protective Equipment(PPE)for this facility includes safety shoes,safety glasses,hearing protection,a reflective safety vest and a hard hat.Inspectors should also bring wheel chocks when inspecting this facility. Applicable Regulations Permit Condition A.1 states that the facility is subject to the following regulations:Title 15A North Carolina Administrative Code (NCAC), Subchapter 2D .0202,2D .0501,213.0510,2D .0521,2D .0524(40 CFR Part 60, Subpart 000),2D.0535,2D.0540,2D .1806 and 2Q.0309.This facility is not subject to the Risk Management Plan(RMP)requirements of the 112(r)Program,as it does not purchase,produce,utilize,or store any of the regulated substances in quantities above their associated threshold limits.The facility is still subject to the General Duty clause in this rule. Discussion The facility is a rock quarrying and sales operation.The facility is permitted for crushing(ES-Crush),screening(ES-Screen)and conveying operations(ES-Convey).The facility was not in operation at the time of this inspection.Mr.Barrett indicated that production at the facility was beginning to slow down as a result of the changing weather.Nevertheless,Mr.Dyson endeavored to inspect the facility at this time due to its upcoming permit expiration on February 28,2022.Mr.Dyson was guided around the facility by Mr.Huss to observe the facility's equipment.The facility's equipment list and plant flow diagram were also provided at the time of this inspection. The list and diagram provided by the facility were dated June 28,2017,which appeared to match the information on file at the WSRO-DAQ.As discovered at the time of this inspection,however,the facility purchased a 26"x44"Premiertrak track- mounted portable crusher with a built-in conveyor in early 2021.According to the facility's daily logs,this portable unit was first placed in operation at the facility on March 9,2021.Mr.Barrett stated that this unit is rated at 60 tons per hour.According to Mr. Barrett,the facility initially brought this portable unit on-site,as they were encountering significant maintenance issues with their primary jaw crusher(Lippman 3042 jaw crusher rated at 150 tons per hour),and wanted to be able to continue operating,albeit at a more limited capacity,while repairing this main crusher.Mr.Barrett stated that this portable crusher was used exclusively to replace the functionality of the main existing jaw crusher and was never operated in conjunction with the existing jaw crusher to increase 2 production. Mr. Barrett explained that the facility initially rented this portable unit,but ultimately decided to purchase the unit outright to keep at the facility if it ever needs to be used as a replacement unit for the primary jaw crusher again in the future.Mr.Barrett acknowledged that this portable crushing unit was not added to the facility's equipment list,and no notifications were sent to the WSRO-DAQ regarding this unit. More information pertaining to this will be conveyed under Permit Conditions A.3 and A.8 below. The portable crushing unit was observed on-site at the time of this inspection,although it was located off to the side of the main crushing area and did not appear to have been operated recently.The remaining crushing,conveying and screening equipment on-site appeared to match that conveyed in the facility's plant flow diagram dated June 28,2017.It should be noted that the facility appeared to be working on re-grading a lot located behind where the portable crushing unit was parked.Mr.Barrett explained that they have been working on this project for a few years,as they hope to lease this land to a concrete company for the purpose of constructing a concrete plant on that lot at some point in the future.Mr.Barrett indicated that this project may take significant time to move forward and reiterated that any future concrete facility on that lot would be separately owned,and they would have to submit their own permit application(or applicability determination)in the future. The facility's exempt 500-gallon capacity aboveground diesel fuel storage tank(IES-2)was observed on-site at the time of this inspection. As noted by previous inspectors,the 2,500-gallon capacity aboveground diesel fuel storage tank(IES-2)is also located on- site. However,this tank(IES-2)sits empty,as it has not been installed at the facility.The facility's 510 kW maximum rated capacity output diesel-fired portable generator(IES-1)was also observed on-site at the time of this inspection.This engine is used to provide power to the facility's crushing process. Mr.Barrett indicated that there are currently no plans to connect the crushing equipment to a local power grid due to the significant expenditure of such a process.This engine,which was not in operation at the time of this inspection, is in a portable trailer beside the facility's jaw crusher.This engine's hour meter read 2782 hours at the time of this inspection. Permit Conditions Condition A.2 contains the permit renewal and emission inventory requirement of 15A NCAC 2D .0202.To meet this requirement, the facility must submit a permit renewal request and air pollution emission inventory report for the 2020 calendar year at least 90 days prior to the expiration date of the permit.The current permit for this facility expires February 28,2022,and the facility's complete permit renewal request is due November 30,2021.Ms.Bach and Mr.Barrett stated that they are aware of the requirements of this condition.Ms.Bach stated that she has prepared the emission inventory and the Form A and will be sending them via certified mail shortly. Condition A.3 contains the equipment reporting requirements of 15A NCAC 2D.0501(c).To comply,the facility is required to maintain on-site an equipment list and plant diagram of all equipment covered under the permit.The equipment list must include unique identification numbers,dates of manufacturing,dates that any required performance testing was conducted and submitted to the DAQ for each applicable piece of equipment,as well as the width of belt conveyors,dimensions and configurations of screens, rated capacity of each crusher and the rated capacity of all equipment not exempt from permit requirements under 15A NCAC 2Q .0102.Under this condition,the Permittee may also install new,or relocate existing nonmetallic mineral processing equipment,as long as such equipment does not change the primary crushing rated capacity of the facility,and the new nonmetallic mineral processing equipment does not utilize any mechanical collection device(s).The facility is required to provide written notification to the Regional Supervisor each time nonmetallic mineral processing equipment is installed or relocated at the facility,at least 15 days prior to installation or within 15 days of relocation.As noted in the discussion section,the facility placed a 60 ton per hour,26"x44" Premiertrak track-mounted portable crusher with a built-in conveyor in operation on March 9,2021.This portable unit was not included on the facility's equipment list or plant flow diagram maintained on-site at the time of this inspection,and no notifications were received at the WSRO-DAQ regarding this unit.The facility appeared to be deficient in meeting the requirements of this condition at the time of this inspection,as they did not provide a written notification of the installation of this equipment or maintain a current equipment list on-site. Condition A.4 contains the particulate control requirement of 15A NCAC 2D .0510.This condition requires the facility to take steps to reduce,to a minimum,any particulate matter from becoming airborne to prevent exceeding the ambient air quality standards beyond the property line.The facility is required to control process-generated emissions from crushers with wet suppression,and from conveyors, screens,and transfer points such that the applicable opacity standards in 15A NCAC 2D .0521,"Control of Visible Emissions," or 15A NCAC 2D.0524, "New Source Performance standards"are not exceeded. The facility utilizes wet suppression to control particulate matter emissions. However,wet suppression was not in active use since the facility was not in operation at the time s of this inspection.The wet suppression lines appeared to be well-maintained at the time of this inspection, and compliance with this i condition is anticipated. 3 Condition A.5 states that the facility's primary crusher is a 30"by 42"jaw crusher rated at 150 tons per hour when operating with its discharge opening set at 3 inches. In accordance with 15A NCAC 2D .0510,any change from this crusher definition,other than like- for-like,will require a permit application to be submitted.The specifications of the facility's primary crusher were confirmed with Mr. Barrett,and this crusher was not in operation at the time of this inspection. Mr.Barrett stated that the facility keeps the jaw setting on this crusher at 2.5".According to Mr.Barrett,the facility's secondary crushers would be overwhelmed if the facility attempted to open the jaw on the primary crusher any further.Compliance is indicated. Condition A.6 contains the visible emissions control requirement of 15A NCAC 2D .0521.Visible emissions from emission sources manufactured after July 1, 1971,shall not exceed 20 percent opacity when averaged over a six-minute period,except that six-minute periods averaging not more than 87 percent opacity may occur not more than once in any hour nor more than four times in any 24- hour period.It should be noted,however,that sources which must comply with 15A NCAC 2D .0524 "New Source Performance Standards",must comply with the applicable visible emissions standards contained therein.No visible emissions were observed by this inspector from any of the facility's equipment,indicating compliance with this condition at the time of this inspection. It should be noted,however,that the facility was not in active operation at the time of this inspection.Therefore,visible emissions will be reassessed during the next field inspection. Condition A.7 contains the visible emissions control requirement of 15A NCAC 2D .0521. Visible emissions from emission sources manufactured as of July 1, 1971,shall not be more than 40 percent opacity when averaged over a six-minute period,except that six- minute periods averaging not more than 90 percent opacity may occur not more than once in any hour nor more than four times in any 24-hour period.Once again, it should be noted that sources which must comply with 15A NCAC 2D .0524 "New Source Performance Standards",must comply with the applicable visible emissions standards contained therein.No visible emissions were observed from any of the facility's equipment,indicating compliance with this condition at the time of this inspection. It should be noted,however, that the facility was not in active operation at the time of this inspection.Therefore,visible emissions will be reassessed during the next field inspection. Condition A.9 contains the notification requirement of 15A NCAC 2D .0535.To comply with this condition,the facility shall notify the Director of any excess emissions that last for more than four hours and that result from any malfunction,breakdown of process or control equipment,or any other abnormal circumstance.Mr.Barrett stated that there have been no such occurrences at the facility since the date of the last inspection,and no notifications regarding excess emissions appear to have been received at the WSRO-DAQ since the date of the last facility inspection. Compliance with this condition is indicated. Condition A.10 contains the fugitive dust control requirement of 15A NCAC 2D .0540.To comply with this condition,the permittee shall not cause or allow fugitive dust emissions to cause or contribute to substantiated complaints or excess visible emissions beyond the property boundary.It should be noted that a fugitive dust complaint attributed to this facility was received at the WSRO-DAQ on March 9,2021.Mr.Dyson discussed this complaint with Mr.Barrett via a telephone call on March 10,2021.At that time,Mr.Barrett stated that the facility had recently commenced operation for the year and were working on stabilizing the process to run as normal. Mr.Barrett stated that he would immediately inspect/adjust the facility's wet suppression systems and would utilize their water tanker truck to wet down dry,unpaved areas.According to the IBEAM database,no other dust complaints appear to have been attributed to this facility.No fugitive dust was observed, indicating compliance with this condition at the time of the inspection. Condition A.11 contains the control and prohibition of odorous emissions requirement of 15A NCAC 2D .1806. To comply with this condition,the permittee must operate the facility in such a manner as to prevent odorous emissions from causing or contributing to objectionable odors beyond the property boundary.No discernible odors were detected during the approach to the facility,and there is no history of odor complaints in IBEAM pertaining to this facility.Compliance with this condition is indicated. Condition A.12 references the requirements for sources exempted from air permitting.This condition states that the facility's 510 kW maximum rated capacity output diesel-fired portable generator(IES-1)is exempt from permitting and exempt from federal stationary source standards(NSPS and NESHAP)due to being defined as a non-road engine.To maintain this exemption from federal stationary source standards,this engine must be re-located at least once per consecutive 12-month period.The facility is also required to maintain records that document each time the location of the engine is changed,as well as the reason for its re-location.The facility's re-location records for this engine were observed and reviewed back to the date of the last facility inspection.According to the provided records,this engine was re-located on September 10,2021,for a ground rod testing issue. Prior to this,the engine was re- located on November 4,2020,March 10,2020,and June 4,2019,due to re-grading around the site.This engine is in a portable trailer beside the facility's jaw crusher.A truck is connected to the trailer to re-locate the engine,as needed. Compliance with this condition is indicated. 4 Condition A.13 states that the DAQ may require the facility to submit additional information upon the Director becoming aware of any credible air emissions data not previously considered by the DAQ during the application review process. Based on this information,the Director may modify and reissue the permit with additional emission controls and/or additional operational restrictions necessary to demonstrate compliance with any applicable regulation.No credible air emissions data not previously considered by the DAQ was uncovered as part of this inspection. NSPS/NESHAP Condition A.8 references the requirements of 15A NCAC 2D .0524,"New Source Performance Standards"for the nonmetallic mineral processing equipment,as promulgated in 40 CFR 60, Subpart 000,including Subpart A,"General Provisions."In summary, this condition references the following requirements of the facility: • Notify the Regional Supervisor, in writing,of the actual date of initial startup of an affected facility,postmarked within 15 days after such date. • A 15%opacity limit is established for any crusher and a 10%opacity limit for conveyor belts,screening operations and other affected facilities constructed,modified,or re-constructed after August 31, 1983,but before April 22, 2008. • A 12%opacity limit is set for any crusher and a 7%opacity limit for conveyor belts,screening operations and other affected facilities constructed,modified,or re-constructed on or after April 22,2008. • The facility is required to perform monthly inspections of the wet suppression systems for sources constructed, modified,or reconstructed on or after April 22,2008.These inspections must be recorded in a logbook and presented to DAQ inspectors upon request. • The facility is required to conduct Method 9 visible emissions testing on affected crushers,conveyors,screening operations and other affected facilities within 60 days after achieving the maximum production rate at which the affected facility(s)will be operated but no later than 180 days after the initial start-up.The facility is also required to submit two copies of a written report of the test(s)to the WSRO-DAQ. This condition also allows for a like-for-like replacement exemption from the provisions of 40 CFR 60.672,60.674 and 60.675, if the existing equipment is replaced by a piece of equipment of equal or smaller size that has the same function as the equipment it is replacing,and the replacement is not expected to result in an increase of overall emissions. As noted in the discussion section,the facility placed a 60 ton per hour,26"x44"Premiertrak track-mounted portable crusher with a built-in conveyor in operation on March 9,2021.This unit was operated solely to fill the role of the facility's jaw crusher during a period of maintenance on the main jaw crusher. Mr. Barrett stated that the facility bought this portable unit outright and it will remain on-site if it ever needs replace the role of the main jaw crusher during future periods of maintenance. It should be noted that the facility did not submit a notification of startup for this portable unit to the WSRO-DAQ. Following discussions with Mr. Davis Murphy,Compliance Supervisor for the WSRO-DAQ, it appears that this portable crusher qualifies as a like-for-like replacement as provided in 40 CFR 60.670(d),as it is used to replace the role of the main primary crusher during periods of maintenance, it is of equal or smaller size than the crusher it is replacing,it has the same function as the existing crusher,and there is no expected increase in the amount of emissions.Therefore,it appears that opacity testing will not be required for this portable crusher.Based on the facility's equipment list,there are only three pieces of equipment at the facility that were constructed after April 22,2008(conveyors 12, 13 and 14).Ms.Bach provided the facility's wet suppression system inspection records as part of this inspection.These records appeared complete and indicated that the facility documents their wet suppression system inspections for each day that the facility is in operation.The most recent inspection record was dated November 2,2021.No visible emissions were observed from any of the facility's equipment at the time of this inspection,as the facility was not actively,crushing,conveying,or screening any materials at that time.The facility appeared to be deficient in meeting the requirements of this condition at the time of this inspection,as they did not provide a notification of startup for the track-mounted portable crusher. Facility-Wide Emissions The following table,borrowed from Permit Review R04(written by Mr. Christopher Lewter,Former Environmental Engineer for the WSRO-DAQ,and dated March 7,2014),conveys the facility's potential and actual emissions for calendar year 2012. Actual Emissions(CY2012) #�Poteutial En'issinns Pollutant .......................... x. PM 0.20 10 50 PM'o �. . 0.14 _ 3.78 5 Actuai�Emass1ons'(CY2012)7, Po ei)ttal tt i szons Pa�lutant M , [ton/"A ] 3 ,Cy '[tVAIU/yr] �Y - ...2. f - .................... PMzs ( 0.11 ( 1.09 S02 0.17 NO, F�------�--�-- 3�.39 CO 0.78 N/A 0.19 HAPTo,ajlb./yr.] F-2.62 HAPx,gnesc[lb./yr.] 1 53 (benzene) Permit Issues/Considerations Permit Condition A.13 may be able to be removed upon the next permit opening,as these requirements are already referenced by Condition B.6. Source Testing The facility conducted visible emissions testing on the dump points to conveyors 12, 13 and 14 on August 28,2013.The highest six- minute average opacity readings were 0%for all three conveyors.A letter was issued to the facility on September 6,2013,stating that the test results show compliance with 40 CFR 60,Subpart 000. 5 Year Compliance History This facility has not been issued a NOD,NOV,or NOV/RE in the past 5 years,according to the IBEAM database. Conclusion Based on visual observations and record review,Alleghany Stone,LLC will be issued a NOD for failing to maintain an updated equipment list on-site as required by 15A NCAC 2D.0501(c),and for failing to provide the notification of start-up for the 60 ton per hour,26"x44"Premiertrak track-mounted portable crusher with a built-in conveyor,as required by 40 CFR 60, Subpart 000. 6